UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

LORETO INNOVATION, INC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF 

THE CODE OF FEDERAL REGULATIONSECTIONS 61.113(a) & (b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING 

COMMERCIAL OPERATION OF THE 3DR & DJI 6 UNMANNED AIRCRAFT 

SYSTEMPURSUANT TO SECTION 333 OFTHE FAA MODERNIZATION AND 

REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on October 18, 2015 

Loreto Innovation LLC.

4200 N. Holton Ave

Milwaukee, WI 53212

Tel: 414-797-1828
TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS ............................................................................................3 

SUMMARY ....................................................................................................................................4 

INTRODUCTION AND INTERESTS OF PETITIONER.............................................................4 

BACKGROUND ............................................................................................................................5 

BASIS FOR PETITION..................................................................................................................5 

NAME AND ADDRESS OF PETITIONER......................................................................7 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH LORETO INNOVATION 

SEEKS EXEMPTION ........................................................................................................7 

THE EXTENT OF RELIEF LORETO INNOVATION SEEKS AND THE REASON 

LORETO INNOVATION SEEKS THE RELIEF ............................................................11 

THE REASONS WHY GRANTING LORETO INNOVATION'S REQUEST WOULD 

BE IN THE PUBLIC INTEREST.....................................................................................13 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY............................................................................................................17 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...............31 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT LORETO INNOVATION'S REQUEST.........................................................31 

CONCLUSION .................................................................................................................32 
AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
SUMMARY

Loreto Innovation, Inc. seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) 

& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) 

& (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Loreto Innovation

to operate an Unmanned Aircraft System (UAS) for the commercial purpose of capturing still 

imagery, video acquisition and digital 3D data capture (hereinafter referred to as “aerial data 

acquisition”). 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Loreto Innovation is one of the fastest growing water technology companies firms in the 

United States. Loreto Innovation provides water resources to include water collection for water 

sampling, temperature, PH level testing, environmental surveying, mapping, and data collection. 

Loreto Innovation's record of technical achievements is enhanced by a reputation for 

effective management and personal service. Loreto Innovation’s clients benefit from receiving 

personal service and local expertise. 

Loreto Innovation has recently acquired a 3DR ArduCopter Hexa unmanned aircraft 

system (hereinafter “3DR”) and a DJI Spreading Wings Hexacopter unmanned aircraft 

(hereinafter named “DJI”) Loreto Innovation has historically used expensive means to acquire 

aerial information. With the advent of unmanned systems (drones) in recent years, Loreto 

Innovation has become dependent on the capabilities of UAS technology. The use of UAS 

technology has allowed flight in ways never before capable with conventional fixed wing and 

rotary vehicles, providing different project perspectives and bridging the gap between traditional 

land-based photography and traditional manned aerial photography. As set forth in this Petition, 

Loreto Innovation seeks to commercially operate its 3DR & DJI over certain areas of the United 

States for the purpose of capturing aerial imagery, video acquisition, water sampling, 

temperature and PH level testing, and 3D data collection. 

BACKGROUND

Unmanned Aircraft System: 3DR & DJI 

Loreto Innovation seeks an exemption to operate the Loreto Innovation 3DR & DJI for 

compensation or hire within the NAS. The 3DR is comprised of a vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA). The 3DR has a maximum gross take- off weight of 

approximately 6.5 pounds [Typical Operating Payload: 3DR (4LB) + 5500mah 3S Batteries (2

LB) + GO PRO Session *& Gimbal (.5LB) while having a diameter of 21.65 inches, height of 18 

inches, and maximum speed of 20 mph (17.37 knots) and a wind tolerance of 15 mph. The 3DR

UA is equipped with six plastic propellers, each of which is driven by a triple bearing, 

dynamically balanced, brushless electric motor and 18amp Electronic Speed Control (ESC) unit. 

The 3DR is powered by 3S (11.2V) 35C at 5,500mah. Flight times range between 16 minutes 

and 22 minutes depending on payloads. 

The DJI is comprised of a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA). 
The 3DR & DJI UAV has a maximum gross take- off weight of approximately 8.5 pounds 

[Typical Operating Payload: DJI (5LB) + 1100mah 6S Batteries (3 LB) + GO PRO Session *& 

Gimbal (.5LB) while having a diameter of 35.82 inches, height of 24 inches, and maximum 

speed of 30 mph (26.07 knots) and a wind tolerance of 25 mph. The DJI UA is equipped with six 

plastic propellers, each of which is driven by a triple bearing, dynamically balanced, brushless 

electric motor and 30amp Electronic Speed Control (ESC) unit. The 3DR is powered by 6S 

(11.2V) 75C at 11,000mah. Flight times range between 15 minutes and 20 minutes depending on 

payloads.

The 3DR & DJI that will be operated by Loreto Innovation will be registered in 

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft 

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration 

Marking. 

BASIS FOR PETITION

Petitioner, Loreto Innovation, Inc., by and through undersigned counsel, pursuant to the 

provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization 

and Reform Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems, 

hereby petitions the Administrator to operate the 3DR & DJI in the National Airspace System 

(NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, Loreto Innovation’s operation of the 3DR & DJI meets the 

conditions of Section 333 and therefore, will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, Loreto Innovation requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. 

Loreto Innovation submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Loreto Innovation will use its authorized technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, 

and practices prescribed in the manufacturer’s maintenance manual. Furthermore, Loreto 

Innovation will document and maintain all maintenance records for the 3DR & DJI. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by Loreto Innovation to the extent 

necessary to allow a Pilot in Command (PIC) who holds a UAV Pilot Certificate that shows 10 

hours of simulator, 16 hours of ground school and 16 hours of flight training for a total of 42 

hours of training, to conduct the proposed UAS flight operations. Loreto Innovation submits that 

the conditions and limitations set forth herein will ensure the safety of the NAS, as well as the 

safety of persons or property on the ground.

Loreto Innovation seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the 3DR & DJI does not require an airworthiness certificate in accordance with 14 
C.F.R. Part 21, Subpart H. As such, Loreto Innovation submits that it will ensure that the 3DR & 

DJI is in an airworthy condition, prior to every flight, by determining that the UAS is in 

compliance with the 3DR & DJI Flight Manual, and that the aircraft is in a condition for safe 

flight. 

Loreto Innovation also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the 3DR & DJI UAV will not have a typical barometric altimeter 

onboard. However, altitude, azimuth, pitch, yaw, heading and speed information of the 3DR & 

DJI UAV will be provided to the PIC via the on-board On- Screen Display (OSD) module and 

Naza Lite Global Positioning System (GPS) which transmits real-time flight information directly

to the PIC’s First Person View (FPV) video monitor mounted to the Ground Control System 

(GCS) for active monitoring of flight operations. This altitude information, combined with 

Loreto Innovation’s operation of the 3DR & DJI UAV within visual line of sight, at or below 

400 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Loreto Innovation seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Loreto Innovation submits 

that safety will not be affected by terminating flights of the battery powered 3DR & DJI after 15-

20 minutes of continuous flight, which would allow for five minutes of battery power remaining. 

In accordance with 14 C.F.R. § 11.81, Loreto Innovation provides the following 

information in support of its petition for exemption: 

A. Name And Address Of The Petitioner. The name and address of the Petitioner is: 

Loreto Innovation, Inc. 4200 North Holton Street, Milwaukee, WI. The point of 

contact for this Petition and specific contact information is as follows: Que El-Amin, 

4200 North Holton Street, Milwaukee, WI 53212 | Tel: 414-797-1828 | 414-736-9036 

Email: que@Loreto.co 

B. The Specific Sections Of 14 C.F.R. From Which Loreto Innovation Seeks 

Exemption. 

1. Loreto Innovation Seeks Exemption From The Requirements Of Section 

61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of 

an aircraft that is carrying passengers or property for compensation or hire; nor may that 

person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if—

(1) The flight is only incidental to that business or employment; and 
(2) The aircraft does not carry passengers or property for compensation or hire. 

2. Loreto Innovation Seeks Exemption From The Requirements Of Section 91.7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Loreto Innovation Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 

part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of 

that aircraft, as the case may be, by reference to an altimeter that is set, when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, 

the current reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure 

airport or an appropriate altimeter setting available before departure; 

4. Loreto Innovation Seeks Exemption From The Requirements Of Section 

91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), 

states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 15 

minutes. 

5. Loreto Innovation Seeks Exemption From The Requirement Of Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each 

owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter[.] 

6. Loreto Innovation Seeks Exemption From The Requirements Of Section 
91.407(a)(1). 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7 of this 

chapter[.] 

7. Loreto Innovation Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following:(a) Except as 

provided in paragraph (c) of this section, no person may operate an aircraft unless, within 

the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by § 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 

21 of this chapter. 

8. Loreto Innovation Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: 

Except for work performed in accordance with §§ 91.411 and 91.413, each registered 

owner or operator shall keep the following records for the periods specified in paragraph 

(b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 

100-hour, annual, progressive, and other required or approved inspections, as appropriate, 

for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance 

of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the work 

performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft for return 

to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 
(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are required 

to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and its appliances 

are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety directives 

including, for each, the method of compliance, the AD or safety directive number and 

revision date. If the AD or safety directive involves recurring action, the time and date 

when the next action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration 

to the airframe and currently installed engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until the 

work is repeated or superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service. 

C. The Extent Of Relief Loreto Innovation Seeks And The Reason Loreto Innovation Seeks 

The Relief. 

1. Extent of Relief Loreto Innovation Seeks And The Reason Loreto Innovation 

Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations:

Pilot in command, is requested to the extent necessary to allow a PIC who holds a UAV Pilot 

Certificate that shows 10 hours of simulator, 16 hours of ground school and 16 hours of flight 

training for a total of 42 hours of training, to conduct the proposed UAS flight operations for 

compensation. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state 

that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any

business or employment if - (1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, Loreto Innovation submits that an equivalent level of 
safety will be maintained because no PIC will be allowed to operate the 3DR & DJI unless that 

PIC has demonstrated, through the UAS training and currency requirements, that the PIC is able 

to safely operate the 3DR & DJI in a manner consistent with the operations specifications as 

described in this exemption, including evasive and emergency maneuvers, as well as maintaining 

appropriate distances from people, vessels, vehicles and structures. 

Further, Loreto Innovation submits that all flights of the 3DR & DJI, conducted by the 

PIC pursuant to the grant of this Petition - (1) will be incidental to Loreto Innovation’s business; 

and (2) will not carry passengers or property for compensation or hire. 

2. Extent of Relief Loreto Innovation Seeks And The Reason Loreto Innovation 

Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow Loreto Innovation to determine that the 3DR & DJI is in an airworthy condition 

prior to every flight by ensuring that the UAS is in compliance with the 3DR & DJI 6 Flight 

Manual, and that the aircraft is in a condition for safe flight. 

Loreto Innovation seeks the requested relief because the 3DR & DJI does not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Loreto 

Innovation will ensure that the 3DR & DJI is in an airworthy condition based upon its 

compliance with the operating documents (i.e., the 3DR & DJI Flight Manual) prior to every

flight, and as stated in the conditions and limitations below. 

3. Extent of Relief Loreto Innovation Seeks And The Reason Loreto Innovation 

Seeks Relief From Section 91.121. 

Relief from Section 91.121 entitled Altimeter settings, may be required to allow flight 

operations of the 3DR & DJI, which utilizes GPS equipment and a radio communications 

telemetry data link to downlink altitude information to the PIC from the UA to the GCS. As 

more fully set forth below, safety will be maintained as a result of the 3DR & DJI altitude 

readout via GPS equipment, and Loreto Innovation’s operation of the 3DR & DJI UAV within 

visual line of sight, at or below 400 feet AGL. 

4. Extent Of Relief Loreto Innovation Seeks And The Reason Loreto Innovation 

Seeks Relief From Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered 3DR & DJI UAV during 

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR) 

conditions, to continue for a total duration of 15 - 20 minutes, which will ensure that the UAV 

will land with five minutes of battery power remaining. Loreto Innovation seeks the requested 

relief because without an exemption from Section 91.151(b), the flight time duration of the 

battery powered 3DR & DJI UAV will severely constrain the practicality of any aerial 

acquisition and flight operations that Loreto Innovation proposes to conduct pursuant to this 

Petition. 

Significantly, as set forth below, the technical specifications of the 3DR & DJI, the 3DR 
& DJI Flight Manual, and Loreto Innovation’s proposed operating limitations, ensure that Loreto 

Innovation will safely operate the battery powered 3DR & DJI UAV during daylight hours in 

VFR conditions, for a total flight duration of 15 - 20 minutes, landing with five minutes of 

battery power remaining. 

5. Extent Of Relief Loreto Innovation Seeks And The Reason Loreto Innovation 

Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 

91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only 

apply to aircraft with an airworthiness certificate, Loreto Innovation requests relief from these 

Sections because the 3DR & DJI does not require an airworthiness certificate. As set forth more 

fully below, the 3DR & DJI meets the conditions of Section 333 of the FMRA for operation 

without an airworthiness certificate. Accordingly, Loreto Innovation will use authorized 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the 

methods, techniques, and practices prescribed in the manufacturer’s maintenance manual. 

Furthermore, Loreto Innovation will document and maintain all maintenance records for the 3DR 

& DJI. 

D. The Reasons Why Granting Loreto Innovation’s Request Would Be In The Public 

Interest; That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing Loreto 

Innovation to safely, efficiently, and economically perform aerial data acquisition commercially, 

in support of DoD, federal, state, local government and private entities in relation, but not limited 

to engineering, environmental, energy, technology, planning, transportation, and land 

development services.

Additionally, use of the 3DR & DJI will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. Notably, the benefits of Loreto 

Innovation’s proposed operation of the 3DR & DJI will be realized without implicating any 

privacy issues. 

1. The Public Will Benefit From Aerial & Underwater Data Acquisition. 

Loreto Innovation submits this Petition to commercially operate the 3DR & DJI and 

perform aerial data acquisition throughout the United States, in support of DoD, federal, state, 

local government and private entities in relation, but not limited to engineering, environmental, 

energy, technology, planning, transportation, and land development services. The 3DR & DJI

will provide safe, efficient, and economical aerial data acquisition to capture project specific 

imagery for project efforts and for use in pursuits. 

The specific operations that Loreto Innovation will perform with the 3DR & DJI

demonstrate how the requested exemption will directly benefit the above-referenced industries 

and the public. In transportation, the aerial data acquisition performed by the 3DR & DJI will be 

used to acquire still images, video and other data. These simulations will be used for public 

outreach and comment and will give the public a realistic simulation of a project’s ultimate build 

out. 
Underwater data

2. The Public Will Benefit From Decreased Congestion Of The NAS. 

The 3DR & DJI UAV is battery powered and serves as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the 

amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use 

of the 3DR & DJI would reduce the amount of manned aircraft in the NAS, reduce noise and air 

pollution, as well as increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 3DR & 

DJI UAV does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft 

conducting aerial survey missions would result in fewer aircraft that must be handled by air 

traffic control during the ground, takeoff, departure, arrival, and landing phases of flight 

operations. 

3. The Public Will Benefit From The Safety And Efficiency Of The 3DR & DJI. 

Conducting aerial acquisitions with the 3DR & DJI, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution generated 

during traditional aerial survey flight operations. By using battery power and electric motors, the 

3DR & DJI produces no air pollution, and is the most viable environmentally conscious 

alternative to the cabin class, six cylinder internal combustion twin engine aircraft that are 

typically utilized for aerial acquisitions, while burning approximately 20-30 gallons per hour of 

leaded aviation fuel. The 3DR & DJI UAV, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UA is propelled by battery powered electric 

motors, rather than an internal combustion engine. 

By using the 3DR & DJI to perform aerial data capture, the substantial risk to life and 

property in the air and on the ground, which is usually associated with traditional manned aircraft 

flight operations, will be substantially reduced or completely eliminated. Aside from the lack of 

flight crew members located onboard the aircraft, the 3DR & DJI UAV (maximum gross take-off 

weight of approximately 10 pounds, a diameter of 35.83 inches and height of 24 inches) has less 

physical potential for collateral damage to life and property on the ground, and in the air, 

compared to the manned aircraft that typically conduct aerial acquisitions (weighing 

approximately 6,500 pounds with a wingspan of approximately 40 feet, a length of 34 feet, and a 

fuel capacity of 180 gallons). 

4. Performing Aerial & Underwater Data Acquisition Operations With The 3DR & 

DJI Will Benefit The Economy. 

In addition to being safe and efficient, the 3DR & DJI is also an economical alternative to 

using manned aircraft to conduct aerial acquisitions. As such, operation of the 3DR & DJI will 

allow United States based companies, like Loreto Innovation, to remain competitive and 

contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and 

the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation 

fuels, U.S. owned and operated companies must adopt new and alternative technology in order to 
remain competitive. Operating the battery powered 3DR & DJI is one such technology that not 

only allows companies greater operational flexibility compared to manned aircraft, but provides 

such flexibility without the high operational cost of a traditional manned aircraft. 

By operating the 3DR & DJI, companies such as Loreto Innovation can remain 

competitive and profitable, and therefore, provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial 

performance of U.S. companies, through commercial use of the 3DR & DJI, provides a stable 

workforce that increases consumer spending; improves local, state, and federal tax revenues; and 

allows companies to invest in research and development in order to remain competitive both in 

the United States and abroad. 

5. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

Loreto Innovation’s proposed operation of the 3DR & DJI will not implicate any privacy issues. 

Specifically, the 3DR & DJI will be operated in accordance with all Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. Most 

significantly, the 3DR & DJI UAV will not be operated closer than 500 feet to any person, 

vessel, vehicle, or structure, which is not directly involved in the operation.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or 

How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided 

By The Rule From Which Loreto Innovation Seeks Exemption. 

1. Reasons Why The 3DR & DJI Meets The Conditions Of The FAA Modernization and 

Reform Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, Loreto Innovation’s operation of the 3DR & DJI meets the 

conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification 

and sets forth requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 

333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rulemaking required by section 332 of 

this Act or the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, 
weight, speed, operational capability, proximity to airports and populated areas, 

and operation within visual line of sight do not create a hazard to users of the 

national airspace system or the public or pose a threat to national security; and 

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for 

the operation of unmanned aircraft systems identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this section that 

certain unmanned aircraft systems may operate safely in the national airspace system, 

the Secretary shall establish requirements for the safe operation of such aircraft systems 

in the national airspace system. 

In seeking this exemption, Loreto Innovation submits that the 3DR & DJI can operate 

safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of 

the 3DR & DJI; (b) the pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The 3DR & DJI Demonstrate Its Safe Characteristics. 

The 3DR & DJI does not create a hazard to users of the NAS or the public, or otherwise 

pose a threat to national security considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The 3DR & DJI. 

The technical specifications of the 3DR & DJI are set forth in the “3DR Manual” & “DJI 

Manual“ attached hereto as Exhibit A and B respectfully. Exhibit A & B contain proprietary

information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). Exhibits to this 

Petition contain proprietary information, and in accordance with 14 C.F.R. § 11.35(b), are not to 

be included in the Federal Docket Management System (FDMS). 

ii. The 3DR & DJI Autonomous Flight And Navigation Modes Enable The 

UAS To Remain Within A Defined Operational Area. 

A complete description of the autonomous modes and methods of navigation of the 3DR 

& DJI is provided in the , the “3DR Manual” & “DJI Manual” attached hereto as Exhibit A & B. 

Exhibit A & B contains proprietary information and is to be held in a separate file pursuant to 14 

C.F.R. § 11.35(b). 

iii. The 3DR & DJI Is Designed For Automatic Return To Launch In The 

Event Of Loss Of The Control Link Or Navigation. 

A complete description of the 3DR & DJI’s automatic return to launch function in the 

event of a break in communication or loss of telemetry data is set forth in the the “3DR Manual” 

& “DJI Manual “ attached hereto as Exhibit A & B. Exhibit A & B contains proprietary

information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). 

b. Flight Operations Of The 3DR & DJI Are Limited To The Line Of Sight Of A 

Certificated Pilot in Command WithA Safety Observer. 
Loreto Innovation will only utilize certificated pilots to act as a pilot in command (PIC) 

of the 3DR & DJI. Additionally, a safety observer will assist all pilots. The PIC must complete 

UAV Pilot Certification that shows 10 hours of simulator, 16 hours of ground school and 16 

hours of flight training for a total of 42 hours of training. Flights Of The 3DR & DJI Will Be 

Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Loreto Innovation proposes to commercially operate the 3DR 

& DJI for the special purpose of conducting aerial data capture over areas of the United States, 

pursuant to the following specific operating limitations: 

1) Operations authorized by this grant of exemption are limited to the following aircraft 

described in the operator’s manual which is a hex rotor aircraft weighing less than 30 

pounds: 3DR & DJI Unmanned Aircraft System. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this grant.

2) The UA may not be flown at an indicated airspeed exceeding 52.14 knots. 

3) The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the operator’s manual. All altitudes 

reported to ATC must be in feet AGL. 

4) The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses. 

5) All operations must utilize a visual observer (VO). The VO may be used to satisfy the 

VLOS requirement, as long as the PIC always maintains VLOS capability. The VO and 

PIC must be able to communicate verbally at all times. The PIC must be designated 

before the flight and cannot transfer his or her designation for the duration of the flight. 

6) The operator’s manual and this grant of exemption must be maintained and made 

available to the Administrator upon request. If a discrepancy exists between the 

conditions and limitations in this exemption and the procedures outlined in the operator’s 

manual, the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operator’s manual. 

The operator may update or revise its operator’s manual. It is the operator’s responsibility

to track such revisions and present updated and revised documents to the Administrator 

upon request. The operator must also present updated and revised documents if it 

petitions for extension or amendment. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted this exemption, then the 

operator must petition for amendment to their exemption. The FAA’s UAS Integration 

Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the 

operator’s manual. 

7) Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the 

aircraft is prohibited from operating until the necessary maintenance has been performed 

and the UAS is found to be in a condition for safe flight. The Ground Control Station 
must be included in the preflight inspection. All maintenance and alterations must be 

properly documented in the aircraft records. 

8) Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics (e.g. replacement of a flight critical component), must undergo a 

functional test flight in accordance with the operator’s manual. The PIC who conducts the 

functional test flight must make an entry in the UAS aircraft records of the flight. The 

requirements and procedures for a functional test flight and aircraft record entry must be 

added to the operator’s manual. 

9) The preflight inspection must account for all discrepancies, i.e. inoperable 

components, items, or equipment, not covered in the relevant preflight inspection sections 

of the operator’s manual. 

10) The operator must follow the manufacturer’s UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements, with particular attention to 

flight critical components that may not be addressed in the manufacturer’s manuals. 

11) Loreto Innovation must carry out their maintenance, inspections, and record keeping 

requirements in accordance with the operator’s manual. Maintenance, inspection, and 

alterations must be noted in the aircraft logbook, including total flight hours, description 

of work accomplished, and the signature of the authorized UAS technician or PIC 

returning the UAS to service. 

12) Loreto Innovation UAS technicians must receive and document training referenced in 

the operator’s manual. 

13) Each UAS operated under this exemption must comply with all manufacturer System 

and Safety Bulletins. 

14) Loreto Innovation maintenance personnel must make a record entry in the UAS 

logbook or equivalent document of the corrective action taken against discrepancies 

discovered between inspections. 

15) The PIC must possess at least a UAV Pilot Certificate that shows 10 hours of 

simulator, 16 hours of ground school and 16 hours of flight training for a total of 42 hours 

of training.

16) The operator may not permit any PIC to operate unless that PIC has demonstrated, 

through the training and currency requirements set forth in the operator’s manual, that the 

PIC is able to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

17) UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 
18) The UAS may not operate within 3 nautical miles of the airport reference point as 

denoted on a current FAA-published aeronautical chart. 

19) The UAS may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

20) If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property and land, or be 

recovered in accordance with the operator’s manual. 

21) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operator’s manual. 

22) The PIC is prohibited from beginning a UAS flight unless (considering wind and 

forecast weather conditions and assuming normal cruising speed) there is enough power 

to fly to the first point of intended landing prior to utilizing battery reserve power. 

23) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under this grant of 

exemption. This COA will also require the operator to request issuance of a Notice to 

Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to 

the operation. 

24) All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. Part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings must be as 

large as practicable. 

25) Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements. 

26) The documents required under 14 C.F.R. 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request. 

27) The UA must remain clear and yield the right of way to all other manned aviation 

operations and activities at all times. 

28) The UAS may not be operated by the PIC from any moving device or vehicle.

29) The UA may not be operated over congested or densely populated areas. These areas 

include but are not limited to the yellow areas depicted on World Aeronautical Charts 

(WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). 

However, aeronautical charts may not reflect pertinent local information. Ultimately, it is 

the PIC’s responsibility to maintain the minimum safe altitudes required by § 91.119. 
30) Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC or VO), vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from debris in the event of an accident. The operator must ensure that nonparticipating 

persons remain under such protection. If a situation arises where nonparticipating persons 

leave such protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the land 

owner/controller has granted permission and the PIC has made a safety assessment of the 

risk of operating closer to those objects and; 

c. Operations near the PIC or VO do not present an undue hazard to the PIC or VO, 

per § 91.119(a). 

31) All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from 

land owner/controller or authorized representative will be obtained prior to the beginning 

of every flight. 

32) Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) 

Would Not Adversely Affect Safety. 

Loreto Innovation submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 3DR & DJI

unless that PIC has demonstrated, through the 3DR & DJI training and currency requirements, 

that the PIC is able to safely operate the 3DR & DJI in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Considering Loreto Innovation’s proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No. 11062); and the 

airmanship skills necessary to safely operate the 3DR & DJI, Loreto Innovation submits that the 

additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for Loreto Innovation’s specific proposed flight 

operations. 

Additionally, the FAA has previously granted relief from Section 61.113(a) and (b) 

specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.
Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138). 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not 

Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because 

prior to every flight, Loreto Innovation will ensure that the 3DR & DJI is in an airworthy 

condition based upon the 3DR & DJIs compliance with its operating documents (i.e., the 3DR & 

DJI (CineWing-6) Flight Manual), and as stated in the conditions and limitations herein. 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be maintained because 

the altitude information of the 3DR & DJI UAV will be provided to the PIC via GPS equipment 

and a radio communications telemetry data link, which downlinks from the UA to the GCS for 

active monitoring of the flight path. This altitude information, combined with Loreto 

Innovation’s operation of the 3DR & DJI UAV within visual line of sight, at or below 500 feet 

AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be 

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude 

initiation point will be established and confirmed for accuracy by the UAS PIC. The FAA has 

previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11112, 11136, 11138). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b) as a result of (1) the technical specifications of the 3DR & DJI; (2) the 

limitations on the proposed flight operations; and (3) the location of the proposed flight 

operations. Accordingly, Loreto Innovation will ensure that it can safely operate the battery 

powered 3DR & DJI UAV during daylight hours, in VFR conditions, for a total flight duration of 

no more than 15-20 minutes, resulting in a landing with five minutes of battery power remaining. 

In a previous Petition for Exemption, in which an operator was utilizing a UA identical in all 

material respects to the 3DR & DJI Loreto Innovation proposes to use, the FAA granted an 

exemption from the requirements of Section 91.151, stating as follows: 

In the event that the UAS should run out of power, it would simply land within the access 

controlled operating area. Given its weight and construction material, the risks are less than 

contemplated by the current regulation. Prior relief has been granted for manned aircraft to 

operate at less than the minimums prescribed in § 91.151 (a), including Exemption Nos. 2689, 

5745, and 10650. In addition, similar UAS-specific relief has been granted an Exemption Nos. 

8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR) conditions. The 3DR & DJI

provides a battery failsafe that commands the UA’s return to the launch point when critical 

minimum voltage is reached. The UAS batteries provide approximately 20-25 minutes of 
powered flight. The FAA agrees with Clayco’s proposal to limit UAS flights to not more than 30 

minutes, or enough battery reserve to ensure that the UAS lands at the ground station with at 

least 20% battery reserve power, whichever happens first. Given the limitations on its proposed 

operations and the location of those proposed operations, a reduced minimum power reserve for 

flight in daylight VFR conditions is reasonable. 

See Exemption No. 11109 at 15. 

Here, as in Exemption No. 11109, the technical specifications of the 3DR & DJI; the limitations 

on the proposed flight operations; and the location of the proposed operations, will ensure that 

Loreto Innovation may safely operate the battery powered 3DR & DJI UAV during daylight 

hours in VFR conditions for a total duration of not more than 20 minutes, and landing with five 

minutes of battery power remaining. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that 

safety is not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. Relief has been granted for manned aircraft to operate at less than the 

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11136, 11138). 

6. Reasons Why An Exemption From The Requirements Of Sections91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. 

In seeking this exemption, Loreto Innovation submits that the equivalent level of safety 

with regard to the regulatory maintenance and alteration requirements established by Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Loreto 

Innovation will use its trained technicians to perform maintenance, alterations, or preventive 

maintenance on the unmanned aircraft system using the methods, techniques, and practices 

prescribed in the manufacturer’s maintenance manual. Furthermore, Loreto Innovation will 

document and maintain all maintenance records for the 3DR & DJI. 

Since the 3DR & DJI will be inspected as prescribed by the manufacturer’s maintenance 

manual, Loreto Innovation will maintain the equivalent level of safety established by Sections 

91.405(a), 91.409(a)(1), and 91.409(a)(2). The Flight Manual for the 3DR & DJI sets forth 

airworthiness requirements for the UA, including preflight and post flight inspections, as well as 

scheduled maintenance in four categories: daily, weekly, monthly, and yearly. 

Likewise, the exemption sought will not adversely affect safety because Loreto Innovation will 

perform maintenance, alterations or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed by the manufacturer’s maintenance manual. The Flight 

Manual for the 3DR & DJI details procedures for each component of the UA, including the 

components of the propulsion system, avionics system, and payload system. 

A complete description of the 3DR & DJI airworthiness and maintenance requirements is 

set forth in the “the “3DR Manual” & “DJI Manual” attached hereto as Exhibit A & B. Exhibit 
A& B contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 

11.35(b). 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 3DR & 

DJI will be performed by Loreto Innovation trained technicians, who will document and 

maintain maintenance records for the 3DR & DJI. 

In consideration of Loreto Innovation’s proposed operating limitations, the most recent 

3DR & DJI 6 Flight Manual, and the technical aspects of the 3DR & DJI, Loreto Innovation

submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 

91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously 

granted relief specific to UAS in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11110, 11112, 11136, 11138). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 29 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Loreto Innovation requests that the 

FAA prescribe special conditions for the intended operation of the 3DR & DJI, which contain 

such safety standards that the Administrator finds necessary to establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 

91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

Such special conditions will permit safe operation of the UA for the limited purpose of 

conducting aerial acquisitions over certain areas of the United States. FMRA Section 333 sets 

forth the requirements for considering whether a UAS will create a hazard to users of the NAS or 

the public, or otherwise pose a threat to national security; and further, provides the authority for 

such UAS to operate without airworthiness certification in accordance with any requirements 

that must be established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.§ 

21.16, for operation of the 3DR & DJI, since the airworthiness regulations of 14 C.F.R. Part 21 

do not contain adequate or appropriate safety standards, due to the novel or unusual design 

features of the aircraft. Section 21.16, entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a 

novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special 

conditions and amendments thereto for the product. The special conditions are issued in 

accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft 

engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that 

established in the regulations. 

See 14 C.F.R. § 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may

prescribe special conditions for Loreto Innovation’s intended operation of the 3DR & DJI, which 
contain such safety standards that the Administrator finds necessary to establish a level of safety

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) 

& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) 

& (b). 

F. Summary That Can Be Published In The Federal Register, stating: The Rules From 

Which Loreto Innovation Seeks Exemption:

Loreto Innovation, Inc. seeks exemption from the requirements of 14 C.F.R Sections 

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b). A Brief Description Of The Nature Of The Exemption 

Loreto Innovation Seeks: This exemption will permit Loreto Innovation, Inc. to 

commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting 

aerial data capture and water samples over areas of the United States. 

G. Any Additional Information, Views, Or Arguments Available To Support Loreto 

Innovation’s Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, Loreto Innovation’s request for exemption may be 

granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create 

a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, Loreto Innovation will operate the 3DR & DJI safely in the 

NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to 

national security. 

CONCLUSION

As set forth herein, Loreto Innovation seeks an exemption pursuant to 14 C.F.R. § 11.61 

and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit 

safe operation of the 3DR & DJI commercially, without an airworthiness certificate, for the 

limited purpose of conducting aerial acquisitions over areas of the United States.By granting 

this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also advancing the interests of the public, by

allowing Loreto Innovation to safely, efficiently, and economically operate the 3DR & DJI

commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Loreto Innovation respectfully requests 

that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R 

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 
(a)(2), and 91.417(a) & (b), and permit Loreto Innovation to operate the 3DR & DJI

commercially for the purpose of conducting aerial data capture. 

Dated: June 5, 2015 

Respectfully submitted, 

Loreto Innovation, LLC. 

Que El-Amin | 4200 North Holton Street, Milwaukee, WI 53212 | 414-797-1828

Appendices:

Appendix A: 3DR APM Hexacopter Instruction Manual

Appendix B: DJI Spreading Wings S900 Instruction Manual

Appendix C: Monthly Maintenance Log

Appendix A
3DR: http://3drobotics.com/wp-content/uploads/2013/06/3DR-APMCopter-Hexa-AssemblyInstructions1.pdf

Appendix B

DJI:	http://www.manualslib.com/manual/836421/Dji-Spreading-Wings-S900.html
Appendix C

UAS	#	

__________________

Date	Issue	

Discovered

Date	Issue	

Addressed

Item	Description	&	

Maintenance	Conducted

Maintenance	

Performed	By

Software	

Updates
Airframe

Engines

Propellers

Camera	

Gimbal

Landing	Gear

Vibration	

Dampening

Other: